Memorandum submitted by Devon Community
Composting Network
1. It's difficult for me to respond to this
review under the framework that is given—especially given
the time frame and the demands on my time.
2. Evidence is asked for—which I do not
have—only years of working with the Agency, primarily in
working on Exemptions from waste licensing—risk assessments—for
prospective sites and meetings with officials over legislation
etc.
3. The first thing to say is that I think that
the job of the Agency is difficult to criticise as they are only
policing some extremely badly drafted legislation that we have
laboured under for more than a decade now. Talking to grass roots
recycling, reuse and composting projects there is enormous frustration
with the legislation and red tape process. Projects, who are trying
to reduce waste and protect the environment come up against the
most ridiculous and often contradictory legislation, Spreading
raw manure around is OK (even though it is potentially highly
polluting) but stabilising it by composting first and then spreading
it requires more legislative control.
4. Trying to run a "zero waste" reuse
centre is fraught with looking at exemptions for every single
material brought in and our local officer was bamboozled by what
to do with mixed buttons as they could be made of plastic, horn,
metal, wood etc—so which exemption did they fit under? We
desperately need a low level exemption—or license for these
small projects. The Agency don't seem to know what alternatives
can be offered to groups.
5. The second thing to say is that in Devon
where I mainly operate I find that the Agency officers have really
tried hard to understand and work with our sector. The attitude
has changed from viewing us as people that needed curbing and
controlling to one where I feel that they are very supportive
of our activities and are aghast at the proposed charges for Waste
Exemptions.
— how successful the Environment Agency
has been in its role as enforcer of environmental regulation and
controls, and how well it manages its wide range of activities;
— whether the Agency operates efficiently
and provides good value for money;
6. I do think it is extraordinary that I am
still getting calls from projects that are told that they cannot
start their project on a proposed site because the Agency tells
them that, "because it is within 250 metres of a sensitive
receptor that they cannot proceed." Rather than advising
them that, "because they are within 250 metres, that they
have to undertake a site specific risk assessment." I have
also heard of numerous instances from other parts of the country,
sometimes a simple plan of the site will suffice—with other
groups a risk assessment undertaken by a third party is needed.
As for good value for money—well it's free for exempt projects
at the moment—which is how we would like it to remain.
— the structure, governance and accountability
of the Agency;
7. The Agency has changed its structure—I
have not noticed this having made any great changes from the way
we work with them. I thought that the local officer would be seeking
advice from other areas when they didn't have the experience,
I don't think that that has been happening very efficiently.
— its relationships with Defra, Defra-sponsored
bodies and the rest of Government, including the Agency's role
in the planning system;
8. I can't really comment on this other than
to say that the Agency always tells me to lobby Defra for changes.
Do Defra listen effectively to the Agency?
— the Agency's relationship with non-Governmental
stakeholders and the general public, and how the Agency monitors
satisfaction with its services;
9. See under comments above
— the Agency's responsibilities for
flood defence and flood mapping, including guidance to the public;
— how the organisational changes brought
about by the Natural Environment and Rural Communities Bill will
affect the role of the Environment Agency;
— how the Agency's work in improving
wildlife habitats will tie in with Natural England's work on biodiversity;
— the Environment Agency's forthcoming
corporate strategy 2006-11.
Devon Community Composting Network
December 2005
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